The FHA has received a reply to the questions it asked in a previous letter to DPD planner and CAC staff Maggi Glowacki, Her answers to our questions are in blue below. The full text of her reply is attached. The Floating Homes Association's SMP Committee is in the process of formulating a reponse to these issues.
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Why is the current language ( "protect residential areas") being removed? What is the new language trying to accomplish?
There is no major change intended with the new language. The word "protect residential areas" does not seem appropriate; uses are governed by the shoreline environment designation and the underlying zone and there are no current or anticipated threats undermining single family residential uses in SFR zones. "Provide" seems to be more appropriate.
Is "without over-water coverage" intended to affect floating homes in some way?
This addition does not change the intent. It is meant to clarify that there should be enough land for a structure to be developed with out any portion of the building extending over the water such as would occur with a cantilevered structure.
Regarding your question about floating homes: The locational criteria are used when determining the appropriate shoreline environmental designation and is sometime based on the underlying zone. The locational criteria do not affect development standards or uses allowed in a particular shoreline environment. However I propose that an additional location criterion be added as follows:
(4) Areas with existing floating home moorage," or something to that effect.
What is the new language trying to accomplish?
There are three parts that will help explain the proposed change:
1. Most of the uses that exist in the Conservancy Management areas are relatively high-intensity uses. Examples of this are the Ballard Locks and the West Point Sewage Treatment plant and some recreational marinas.
2. Also, there are some parks located in the current CM environment. Some of these parks have less intense uses than the locks or the sewage treatment plant and some park uses are comparable in the intensity of the uses. Therefore we have proposed to re-designate the parks that are less intensely used (as listed on the map of proposed environmental designation changes) from CM to Conservancy Recreation.
3. When rewriting the purpose of this shoreline environment the original language does not seem possible to achieve, given the existing uses in these areas; therefore, we proposed the more achievable language. However, we do not see this as softening the environmental protection. The section of the purpose statement that states "The types of development allowed in the CM environment can be managed to preserve ecological functions and typically provide public access": This The sentence is to provide guidance on what are the appropriate types of uses that should be allowed in the area and the word "can" means the types of uses that are allowed have the ability to be managed to preserve ecological functions, it is not meant to be an optional term. Overall the purpose of this shoreline environment is meant to convey that these sites may be highly altered and therefore, a more engineered management of the site is required to preserve and protect the aquatic environment in these areas.
To be more clear I suggest that we change the sentence that reads "The types of development allowed in the CM environment can be managed to preserve ecological functions and typically provide public access." To "The types of development allowed in the CM environment are such that they are able to be managed to preserve ecological functions and provide public access
Why was reference to "sensitive areas" removed from the wording?
Regarding the existing language all of our shorelines can be considered sensitive areas but there are varying degrees of sensitivity. For example eel grass would be considered a more sensitive area than areas where eel grass does not occur. The existing code language calling out sensitive areas as appropriate for a higher intensive use does not make sense and we do not believe that that was the intent. We also do not want to continue with this somewhat confusing language that gives a false impression that we should be concentrating heavy infrastructure in particularly sensitive areas of the shoreline.
Therefore we removed the term "sensitive areas" because we do not want to locate a more intense use such as the locks or a sewage treatment plant in sensitive areas such as near eel grass beds. These more intense uses should be located in areas that are more altered or disturbed.
Why was the specific environmental language deleted and the requirement for active management of the specified waterfront lots softened?
The existing language referencing natural resources was deleted because all of our shorelines serve as migration corridors and feeding areas for fish, therefore this locational criterion does not serve a purpose. Regarding including "active management" to the criterion, as explained in my response above, the CM areas are more intensely used and the environmental conditions in this shoreline environment are more altered; therefore, a more active management of these areas to protect and preserve the ecological function of these sites is needed.
Could the current language constitute a (4) in order to preserve its implicit ecological directive?
As explained above, we feel that the overarching environmental directive of the Shoreline Master Program is achieved with the current proposed language. It is only clarified to convey the higher intensity of uses in the Conservancy Management areas as compared to other Conservancy designated shoreline environments.
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